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. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner. ...

. … Canco was deemed to realize a gain in Year 3… equal [to] the total of amounts deducted by Canco under paragraph 113(1)(d) in respect of Forco dividends received through LP that were paid out of Forco's pre-acquisition surplus, less any foreign tax paid in respect of Canco's share of those dividends. ...

. … [I]n 2009-033576, there was no withdrawal from the RRSP. ...

And finally: … only the part of the property taxes attributable to the renovation period that are related to the ownership of the land subjacent to the building, as well as any land meeting the requirements of subparagraph 18(3.1)(a)(ii), should be added to the cost of the building. ...

. … Consequently, a testamentary trust cannot designate a benefit in its income tax return without ensuring that it constitutes an amount that would have otherwise been eligible under paragraph 60(j) for a beneficiary if the beneficiary had received it. ...

. … Usually…installation is seen as being performed in relation to a tangible property, such as a machine or equipment, and…installation should be the main activity of the project to qualify as an "installation project". ...

. … [T]he GAAR should not apply to the situation in this case because subsections 103(1) and (1.1) are of sufficient breadth to adjust the income-sharing terms agreed between the partners of the partnership. ...

According to … Copthorne, in determining whether a transaction is part of a series of transactions or events, it is necessary to determine whether the related transaction is carried out because of the series of transactions or events. ...

A, the Directorate first noted that “For this provision to apply, the CRA must establish that the disposition of Class "F" shares of the capital stock of Opco … was part of the series of transactions or events in which Opco acquired the Class "AA" shares of its capital stock for consideration less than their fair market value,” and then stated: Although the “because of” or “in relation to” test [in Copthorne] of related transactions does not require a strong nexus, it does require more than a mere possibility or a connection with an extreme degree of remoteness. ...

12 January 2015 Internal T.I. 2014-0560421I7- FX losses on CFA wind-up-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) s. 40(3.6) not specifically ousted on s. 88(3) winding-up – but no affiliation after disposition In 2014-0538591I7, the Directorate indicated that s. 40(3.6) did not apply to deny a loss realized on the winding-up of a controlled foreign affiliate because (1) s. 69(5)(d) specifically ousts the application of s. 40(3.6) respecting property (the CFA's shares) disposed of on a winding-up, and (2) it is unlikely that under the foreign corporate law the CFA would be considered to still exist immediately after that disposition. ...